Traffi
Glove – Privacy Policy
Introduction
We take
your privacy very seriously. Please read this privacy policy carefully as it
contains important information about who we are and how and why we collect,
store, use and share your personal data. It also explains your rights in
relation to your personal data and how to contact us or supervisory authorities
in the event you have a complaint.
Controller
Traffi
Safe Limited (“Traffi”,
"we", "us" or "our" in this privacy policy”) is
the data controller and is responsible for certain personal data about you that
we collect and use as a consequence of providing our products to the
organisation that you represent or to you as an individual consumer or as a
consequence of you participating in a trial of our product in accordance with
our terms, or where you use or browse our website as a user.
Capitalised
terms in this privacy policy shall have the same meaning as in the terms, or as
defined in the Key Terms table below.
We keep our privacy
policy under regular review. This version was last updated on 13/07/2023.
This
website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties
to collect or share data about you. We do not control these third-party
websites and are not responsible for their privacy statements. When you leave
our website, we encourage you to read the privacy policy of every website you
visit
Key Terms
It would
be helpful to start by explaining some key terms and references used in this
policy:
Data
protection contact |
|
Data
subject |
The individual who the personal data
relates to, for the purposes of this policy can be representatives of
corporate customers, consumers, participants in product trials, website users. |
Personal
data |
Any information relating to an
identified or identifiable individual. |
You,
your |
Data subject who this policy applies
to |
Personal data we collect
about you
We may
collect a variety of information about you depending on what the status of our
relationship with you is. We have summarised the different kinds of personal data
collected for each of the categories of Data Subject that this policy applies
to:
1.
Representatives of corporate customers (Traffi Distributors) and
representatives of end users
- Identity Data:
includes name and job title.
- Contact Data:
includes business address, email address and telephone numbers.
- Profile Data:
includes your username, password, orders made by you on behalf of your
organisation, your interests, preferences, feedback and demographic
information such as postcode.
�
Usage
Data includes information about
how you use our website and products.
- Marketing and Communications Data includes
your preferences in receiving marketing from us and our third parties and
your communication preferences
- Identity Data:
includes name and title.
- Contact Data:
includes home address, email address and telephone numbers, delivery
address.
- Profile Data:
includes your username, password, trials that you have participated in,
your interests, preferences, feedback and demographic information such as
postcode.
3.
Website users
- Technical Data: includes your computer’s Internet Protocol (IP)
address, your browser type and version, the pages you visit, the time and
date of your visit, the time spent on each page, the device type,
operating system, unique device identifiers, device settings, and geo-location
data.
�
Usage Data:
information about how you use our website, IT, communication and other systems.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose.
Aggregated data could be derived from your personal data but is not
considered personal data in law as this data will not directly or indirectly
reveal your identity. For example, we may aggregate your Usage Data to
calculate the percentage of users accessing a specific website feature.
However, if we combine or connect aggregated data with your personal data so
that it can directly or indirectly identify you, we treat the combined data as
personal data which will be used in accordance with this privacy policy.
We do not collect any “Special Categories” of personal data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership,
information about your health, and genetic and biometric data). Nor do we
collect any information about criminal convictions and offences.
We collect
and use this personal data for the purposes described in the section ‘how
and why we use your personal data’ below. If you do not provide personal data we ask for, it
may delay or prevent us from providing products
to you or your organisation, or engaging you or to participate in a product
trial.
How your personal data is
collected
We collect
some of this personal data directly from you in person for example by
telephone, email and/or via our website or if you
attend an exhibition or trade show and give your details to us. However,
we may also collect information:
•
from
publicly accessible sources, such as publicly accessible websites for example
LinkedIn;
•
from
third parties for example Traffi Distributors may give us information about end
users;
•
from
cookies on our website—for more information on our use of cookies, please see
our cookie policy
How and why we use your
personal data
Under data
protection law, we can only use your personal data if we have a lawful basis
eg:
•
for
our legitimate interests or those of a third party;
•
where
you have given consent;
•
to
comply with our legal and regulatory obligations; or
•
for
the performance of a contract with you or to take steps at your request before
entering into a contract.
A
legitimate interest is when we have a business or commercial reason to use your
personal data, so long as this is not overridden by your own rights and
interests. We will carry out an assessment when relying on legitimate
interests, to balance our interests against your own.
The table
below explains how and why we use your personal data.
What we
use your personal data for |
Lawful
basis |
Type of
data |
To
register you as a new customer (representing tTraffi Distributors or end
users) and to set up an account |
(a) Performance of a
contract with you (b)
Necessary for our legitimate interests (to operate our business) |
Identity Contact Profile Marketing |
To
process your organisation’s order and deliver our product |
(a) Performance of a
contract with you (b)
Necessary for our legitimate interests (operate our business) |
Identity Contact Profile Marketing Transaction
|
To
engage you to participate in a trial of our products |
(a) Performance of a
contract with you (b) Necessary for our
legitimate interests (operate our business) |
Identity Contact Profile
|
To
manage our relationship with you or with you organisation and to develop,
enhance and improve our business. |
(a) Performance of a
contract with you (b) Necessary to comply
with a legal obligation (c) Necessary for our
legitimate interests (to keep our records updated and to study how customers
use our products) |
(a) Identity (b) Contact (c) Profile (d)
Marketing and Communications |
Carrying
out marketing to you and product recommendations. |
Where
you have provided us with your consent For our
legitimate interest, i.e. to develop and grow our business |
Identity
Contact Marketing
|
Preventing
and detecting fraud against you or us |
For our
legitimate interest, ie to minimise fraud that could be damaging for you
and/or us
To
comply with our legal and regulatory obligations. |
Identity Contact Financial |
To
enforce legal rights or defend or undertake legal proceedings, or to provide
information required relating to audits, enquiries or investigations by
regulatory bodies. |
To
comply with our legal and regulatory obligations; For our
legitimate interests, ie to protect our business, interests and rights to
comply with our legal and regulatory obligations |
Identity Contact Profile Financial
|
Operational
reasons, such as improving efficiency, training quality control and security
of our website. |
For our
legitimate interests , ie to be as efficient as we can so we can deliver the
best service to you at the best price |
Identity Contact Technical Usage
|
Statistical
analysis to help us manage our business |
For our
legitimate interests, ie to be as efficient as we can so we can deliver the
best service to you at the best price |
Technical Usage |
Marketing
We may use
your personal data to send you marketing communications and updates about our products.
You have
the right to opt out of receiving marketing communications at any time by
clicking on the unsubscribe link within our emails.
We will
always treat your personal data with the utmost respect and never sell it to other organisations for marketing
purposes.
Who we share your personal
data with
We
routinely share personal data with:
•
third
parties we use to help deliver our products,
eg payment service providers;
•
other
third parties we use to help us run our business, eg marketing agencies or
website hosts and IT and systems administrators;
•
our
bank.
We only allow those organisations to handle your personal
data if we are satisfied they take appropriate measures to protect your
personal data.
We or the
third parties mentioned above occasionally also share personal data with:
•
our
external auditors, eg in relation to the audit of our accounts, in which case
the recipient of the information will be bound by confidentiality obligations;
•
our
and their professional advisors (such as lawyers and other advisors), in which
case the recipient of the information will be bound by confidentiality
obligations;
•
law
enforcement agencies, courts, tribunals and regulatory bodies to comply with
our legal and regulatory obligations;
•
other
parties that have or may acquire control or ownership of our business (and our
or their professional advisers) in connection with a significant corporate
transaction or restructuring, including a merger, acquisition, asset sale, initial
public offering or in the event of our insolvency—usually, information will be
anonymised but this may not always be possible. The recipient of any of your
personal data will be bound by confidentiality obligations.
Where your personal data is
held
Personal
data may be held at our offices and those of our third
party agencies, service providers, representatives and agents as described
above.
Some of
these third parties may be based outside the UK. For more information,
including on how we safeguard your personal data when this happens, see below.
How long your personal data
will be kept
Please contact us: [email protected] if you want further information about how long we will
retain your personal data.
Transferring your personal
data out of the UK
It is
sometimes necessary for us to transfer your personal data to countries outside
the UK. In those cases we will comply with applicable UK laws designed to
ensure the privacy of your personal data.
�
We will only transfer your personal data to countries that
have been deemed to provide an adequate level of protection for personal data;
or
�
Where we use certain service providers, we may use specific
contracts approved for use in the UK which give personal data the same
protection it has in the UK.
Please contact us: [email protected]if you want further information on the specific mechanism
used by us when transferring your personal data out of the UK.
Your rights
You have
the following rights, which you can exercise free of charge:
Access |
The
right to be provided with a copy of your personal data |
Rectification |
The
right to require us to correct any mistakes in your personal data |
Erasure
(also known as the right to be forgotten) |
The
right to require us to delete your personal data—in certain situations |
Restriction
of processing |
The
right to require us to restrict processing of your personal data in certain
circumstances, eg if you contest the accuracy of the data |
Data
portability |
The
right to receive the personal data you provided to us, in a structured,
commonly used and machine-readable format and/or transmit that data to a
third party—in certain situations |
To
object |
The
right to object: —at any
time to your personal data being processed for direct marketing (including
profiling); —in certain
other situations to our continued processing of your personal data, eg
processing carried out for the purpose of our legitimate interests unless
there are compelling legitimate grounds for the processing to continue or the
processing is required for the establishment, exercise or defence of legal
claims |
Not to
be subject to automated individual decision making |
The
right not to be subject to a decision based solely on automated processing
(including profiling) that produces legal effects concerning you or similarly
significantly affects you |
The
right to withdraw consents |
If you
have provided us with a consent to use your personal data you have a right to
withdraw that consent easily at any time Withdrawing
a consent will not affect the lawfulness of our use of your personal data in
reliance on that consent before it was withdrawn |
If you
would like to exercise any of those rights, please:
•
Email:
[email protected]
•
provide
enough information to identify yourself and any additional identity information
we may reasonably request from you; and
•
let
us know what right you want to exercise and the information to which your
request relates.
How to contact us
Please
contact us if you have any queries or concerns about our use of your personal
data. We hope we will be able to resolve any issues you may have.
You also
have the right to lodge a complaint with the Information Commissioner, who may
be contacted using the details at https://ico.org.uk/make-a-complaint
or by telephone: 0303 123 1113.
Last
reviewed : 13/07/2023
Next
review date: 15/07/2024